Barnett v. Louisiana Department of Health

CourtDistrict Court, M.D. Louisiana
DecidedMarch 10, 2023
Docket3:17-cv-01793
StatusUnknown

This text of Barnett v. Louisiana Department of Health (Barnett v. Louisiana Department of Health) is published on Counsel Stack Legal Research, covering District Court, M.D. Louisiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Barnett v. Louisiana Department of Health, (M.D. La. 2023).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF LOUISIANA

MICHELLE BARNETT CIVIL ACTION VERSUS NO. 17-1793-JWD-SDJ LOUISIANA DEPARTMENT OF HEALTH

SUPPLEMENT TO RULING AND ORDER This matter comes before the Court on the Motion for Summary Judgment Pursuant to Fed. R. Civ. Proc. 56 on Plaintiff’s Remaining Claims (the “Motion”) (Doc. 58) filed by Defendant the Louisiana Department of Health (“LDH” or “Defendant”). Plaintiff Michelle Barnett (“Barnett” or “Plaintiff”) opposes the Motion. (Doc. 68.) Among other things, Defendant filed a Local Rule 56(d) Reply Statement of Material Facts, in which Defendant objects to Plaintiff’s individual statements of fact and requests that the challenged statements of fact be stricken under M.D. La. Local Rule 56(e). (Doc. 69-1 at 1.) Because Defendant has submitted numerous objections in this case, the Court has decided to issue this supplement to the ruling and order on the Motion, (Doc. 74), to separately address the preliminary evidentiary issues raised by Defendant. I. Preliminary Evidentiary Issues Defendant specifically objects to certain parts of three affidavits filed on behalf of Plaintiff in support of her opposition to Defendant’s Motion. (See Doc. 69-1 at 2–26.) The affidavits objected to are by Michelle Barnett, (Doc. 68-2), Kelly McNabb, (Doc. 68-3), and Catherine Altazan, (Doc. 68-4). Defendant argues that the objected-to parts of the affidavits should be excluded from the Court’s consideration on the following grounds: “(1) hearsay; (2) self-serving testimony; (3) relevance; (4) lack of personal knowledge; and (5) improper lay opinion on ultimate legal issue.” (Doc. 69-1 at 2.)

At the outset, the Court notes that a majority of the facts objected to are immaterial for purposes of the Motion. Though the Court has reviewed all of the evidence, the Court will not detail a ruling on every evidentiary objection Defendant made, as doing so would not be a wise use of judicial resources. Instead, the Court will first provide an overview of the principles it utilized in deciding what evidence to consider, and then rule on only the objections pertaining to facts that are relevant to the Court’s analysis of Plaintiff’s claims.

A. Relevant Legal Principles In ruling on Defendant’s objections, the Court will refer to and rely on the following principles of law. 1. Legal Principle #1 “Rule 56(c)(4) provides that when affidavits are used to support or oppose a summary- judgment motion, they ‘must be made on personal knowledge, set out facts that would be admissible in evidence, and show that the affiant or declarant is competent to testify on the matters

stated.’ ” 10B Charles Alan Wright & Arthur R. Miller, Federal Practice and Procedure § 2738 (4th ed.) (quoting Fed. R. Civ. P. 56(c)(4)). 2.Legal Principle #2 Note, however, that Rule 56(c)(2) states: “A party may object that the material cited to support or dispute a fact cannot be presented in a form that would be admissible in evidence.” Fed. R. Civ. P. 56(c)(2) (emphasis added).

3. Legal Principle #3 The Fifth Circuit has explained: “Although the substance or content of the evidence submitted to support or dispute a fact on summary judgment must be admissible ..., the material may be presented in a form that would not, in itself, be admissible at trial.” 11 Moore's Federal Practice–Civil ¶ 56.91 (2017); see also Fraternal Order of Police, Lodge 1 v. City of Camden, 842 F.3d 231, 238 (3d Cir. 2016) (holding that a “proponent need only ‘explain the admissible form that is anticipated” (quoting Fed. R. Civ. P. 56, advisory committee's note to 2010 amendment)); Humphreys & Partners Architects, L.P. v. Lessard Design, Inc., 790 F.3d 532, 538 (4th Cir. 2015) (recognizing that a “court may consider ... the content or substance of otherwise inadmissible materials where the ‘the party submitting the evidence show[s] that it will be possible to put the information ... into an admissible form.” (alteration in original) (quoting 11 James Wm. Moore et al., Moore's Federal Practice–Civil ¶ 56.91[2] (3d ed. 2015))); Jones v. UPS Ground Freight, 683 F.3d 1283, 1293–94 (11th Cir. 2012) (determining that a district court may consider a statement “if the statement could be reduced to admissible evidence at trial or reduced to admissible form.” (citation omitted)).

Lee v. Offshore Logistical & Transp., L.L.C., 859 F.3d 353, 355 (5th Cir. 2017), as revised (July 5, 2017). 4. Legal Principle #4 Whether the statements as made by the declarant are hearsay is not relevant in the summary judgment context, because at this stage “materials cited to support or dispute a fact need only be capable of being ‘presented in a form that would be admissible in evidence.’ ” LSR Consulting, LLC v. Wells Fargo Bank, N.A., 835 F.3d 530, 534 (5th Cir. 2016) (quoting Fed. R. Civ. P. 56(c)(2)). And Plaintiff asserts the substance of the relevant statements can be presented at trial in admissible form either through the declarant's testimony, the testimony of TEA members, or the testimony of Comptroller personnel . . . . Moreover, Defendant's objections here are more properly suited to the trial context where the disputed evidence in the precise form sought to be admitted can by analyzed in its full context. For evidence to be proper at the summary judgment stage it does not need to be admissible in the exact form presented, but merely capable of being “presented in a form that would be admissible.” Fed R. Civ. P. 56(c)(2).

Texas Ent. Ass'n, Inc. v. Hegar, No. 17-594, 2019 WL 13036162, at *15 n.12 (W.D. Tex. Feb. 27, 2019), aff'd, 10 F.4th 495 (5th Cir. 2021); see also Humphrey v. Tidewater GOM, Inc., No. 20- 817, 2022 WL 2912561, at *8 (M.D. La. July 22, 2022) (deGravelles, J.) (considering hearsay evidence for summary judgment purposes); In re TK Boat Rentals, LLC, 411 F. Supp. 3d 351, 374 (E.D. La. 2019) (allowing emails between counsel and a declaration confirming the authenticity and content of the emails to be admitted as evidence in ruling on summary judgment motion, holding that “[b]ecause the content of the emails may be presented in a form admissible at trial, [the] declaration and the emails are competent summary judgment evidence”); Ali v. Dist. Dir.,

209 F. Supp. 3d 1268, 1276 (S.D. Fla. 2016) (“Nevertheless, a district court may consider a hearsay statement in passing on a motion for summary judgment if the statement could be reduced to admissible evidence at trial or reduced to admissible form. . . . The most obvious way that hearsay testimony can be reduced to admissible form is to have the hearsay declarant testify directly to the matter at trial.”) (citations and internal quotations omitted). For our purposes here, it is only necessary to consider whether the disputed evidence can

be presented in a form admissible at trial. In re TK Boat Rentals, LLC, 411 F. Supp. 3d at 374. And, as stated by the court in Ali v.

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Barnett v. Louisiana Department of Health, Counsel Stack Legal Research, https://law.counselstack.com/opinion/barnett-v-louisiana-department-of-health-lamd-2023.